How Do I Handle a Criminal Tax Investigation By The IRS? Paying taxes is a part of life in the United States of America and doing so accurately is crucial. When taxes are not correctly completed or are avoided altogether, the IRS has certain processes in place to ensure the mistake is caught and remedied. … Read more
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Recent Injunctions Updates To Beneficial Ownership Reporting Requirements Breaking Down The Latest Changes To BOI Requirements In 2024 Over the years there has been significant concern about the illicit activities that are happening behind corporations. In 2020, discussions became more serious as they worked towards a method to create more transparency within corporations. In 2021, … Read more
What Should I Do If I Disagree With The Outcome Of An IRS Audit? Learn Your Legal Options To Dispute IRS Audit Results An IRS audit can be a stressful and overwhelming experience, even when you’ve done everything right. Despite your best efforts to file accurately, the IRS may still incorrectly conclude that you owe … Read more
4 Tax Schemes From The IRS’s “Dirty Dozen” List That Can Get The Average Taxpayer In Serious Trouble On June 1 of this year, the Internal Revenue Service announced its “Dirty Dozen” list for 2022, which is a list of tax avoidance schemes that taxpayers should avoid filing on their returns. These potentially abusive arrangements … Read more
How The Qualified Small Business Stock Exclusion Can Benefit Business Owners When Selling Tax Relief Opportunities & Requirements For Selling Under Section 1202 When it comes to selling a business, it is essential to consider how the capital gains from the sale will affect your taxes. How much is taken out … Read more
New Jersey Committee Offers New Guidelines For CPAs & EAs On BOI Filings In January 2024, the Corporate Transparency Act went into effect impacting roughly 32.6 million businesses in the United States. The goal is to gain more transparency and fight illegal activity that often happens behind the walls of a company. The CTA will … Read more
What Are The Potential Consequences Of The Supreme Court Transferring Regulatory Power From Agencies To Judges? In June, the Supreme Court considered and overturned the Chevron vs. Natural Resources Defense Council decision which was decided in 1984. This overturning is significant as it could make it easier to bring the regulations set by an agency … Read more
Supreme Court Upholds Tax On Unrealized Gains: Key Implications For Investors On June 20th of this year, the Supreme Court made the decision to uphold the mandatory repatriation tax which allows taxes on unrealized gains, specifically in certain contexts. The issue was brought to court in the case of Moore v. United States. This case … Read more
What Documentation Is Needed For Innocent Spouse Relief? When you are married and file jointly, you and your spouse are jointly responsible for your tax debt. But what if your spouse handles the finances and either underreported income or did not pay a tax debt without your knowledge? It could lead to some serious consequences … Read more
Dirty Dozen Tax Scams: Be Careful Of ‘Mills’ Pushing IRS Debt Solutions Included in the yearly Dirty Dozen list of tax scams, the Internal Revenue Service (IRS) has once again issued a cautionary message to taxpayers regarding costly Offers in Compromise (OIC) “mills” that actively mislead taxpayers by falsely promising the elimination of their tax … Read more
IRS Recovers Funds From Fraudulent COVID Tax Credit Program Despite the IRS’s efforts to reclaim improperly distributed funds through the Employee Retention Credit (ERC), the program intended to help businesses keep employees during pandemic shutdowns was exploited by scammers due to its complex eligibility rules. Its complex eligibility rules allowed scammers to target small businesses, … Read more
Shocking Court Verdict Shakes Corporate America: Alabama Ruling on CTA Could Change Everything! In an unexpected and landmark decision, the U.S. District Court for the Northern District of Alabama recently found the Corporate Transparency Act (CTA) unconstitutional, stirring significant discourse within the legal and business communities. This ruling, alongside the Department of Justice’s subsequent appeal … Read more
Alabama Court Ruling On The CTA: Implications On Nationwide BOI Reporting Companies March 1, 2024, marked a pivotal moment in the legal landscape as a federal judge in Alabama’s Northern District Federal Court issued a significant ruling regarding the Corporate Transparency Act (“CTA“) declaring it unconstitutional. This act, along with its associated regulations, mandates that … Read more
Alabama Ruling Sends Shockwaves Through U.S. Business Regulations! A recent ruling from the Alabama Federal District Court has raised significant questions about the Corporate Transparency Act (CTA) and its implications for federal authority and business regulation. This decision challenges the core of the CTA and sets a precedent that could profoundly impact businesses nationwide. In … Read more
Billionaires’ Secret Exposed: IRS Targets Luxury Jets in New Audit Blitz! The Inflation Reduction Act was passed in 2022 and as a part of it, the IRS was given funds to implement more resources towards seeking out high-income individuals who are not paying their fair share in taxes. One of the ways the IRS is … Read more
IRS’s Game-Changing Plan To Extract $561 Billion From The Elite! On February 6, 2024, the IRS released a new analysis stating that the amount of unpaid and overdue taxes they expect to collect from 2024 to 2034 is hundreds of billions of dollars more than previously stated. The new information was brought forth as a … Read more
Do You Need to Include Your Company Applicant in Your BOI Report Submission? In 2021, the United States enacted the Corporate Transparency Act (CTA), mandating that US-registered companies disclose information on their beneficial owners. This legislation took effect on January 1, 2024, and its enforcement falls under the jurisdiction of the Financial Crimes Enforcement Network … Read more
The Legal Implications of Submitting False Data in CTA Reports The Corporate Transparency Act, established in 2021 and implemented starting January 1, 2024, aims to curb illicit activities like money laundering, terrorist financing, and tax evasion, which were previously concealed under the guise of LLCs or corporations. Under this act, companies are obliged to disclose … Read more
IRS’s Bold Crackdown: Millionaires and Mega-Corporations in the Crosshairs for Tax Evasion! The IRS has been actively working to pursue 1,600 millionaires each owing $250,000 or more in overdue taxes as well as 75 business partnerships that claim $10 billion each in assets. On January 12th, they shared their progress, reporting they have collected $360 … Read more
A Guide For BOI Reporting: Who Qualifies As A Beneficial Owner Of A Business? In 2021, Congress passed the Corporate Transparency Act requiring businesses to report their beneficial owners starting January 1, 2024. It is estimated that 32 million businesses in the USA will be affected. The Beneficial Ownership Information Report will be required from … Read more
How to Ensure Your Business is Prepared for the Corporate Transparency Act? The Corporate Transparency Act (CTA) was enacted on January 1, 2021, to combat money laundering, financially supporting terrorism and other criminal activities. All registered US business entities that are in the “reporting company” category must disclose any beneficial ownership information to the Financial … Read more
The Corporate Transparency Act & Small Businesses: New Reporting Requirements Explained Beginning January 1, 2024, a significant update in reporting requirements will come into effect. This change mandates that roughly 32 million small businesses submit a Beneficial Ownership Information (BOI) report to the Financial Crimes Enforcement Network (FinCEN) under the newly enacted Corporate Transparency Act … Read more
A Comprehensive Business Guide on the Corporate Transparency Act The Corporate Transparency Act (CTA) is set to come into effect on January 1, 2024. This significant law will have an impact on various entities, especially small businesses. These business owners must understand and prepare for the upcoming beneficial ownership information (BOI) reporting obligations. How the … Read more
IRS Sounds the Alarm: The Growing Tax Gap and Its Implications! The Internal Revenue Service has released updated tax gap projections for tax years 2020 and 2021. Their current data reflects a significant increase from previous tax gaps. The agency estimates a tax gap of $192 billion from tax years 2014-2016 and $138 billion from … Read more
OnlyFans Stars & Other Social Media Influencers Beware of IRS Audits & Criminal Investigations OnlyFans has gained tremendous popularity over the past several years, especially during the COVID-19 pandemic when people were home with time on their hands. If you are an OnlyFans Star or are a social media influencer on another site, the IRS … Read more
Is Your Business Next? How the IRS’s AI Targets Partnership Discrepancies! Earlier this month, the IRS announced that it will be utilizing some of its expanded funding from the Inflation Reduction Act to enhance tax compliance across key areas. Their intended focus at this time is business partnerships and high-income taxpayers. The agency has stated … Read more
Billionaires’ Worst Nightmare: IRS Unleashes AI To Track Down Mega Tax Debts Last week, the IRS announced its newest effort aimed at aggressively pursuing 1600 millionaires who each owe $250,000 or more, along with 75 business partnerships with assets averaging $10 billion each, who collectively owe hundreds of millions in overdue taxes. The agency will … Read more
Big IRS Update: Essential E-Filing Changes Every Business Should Be Aware Of The Internal Revenue Service (IRS) has announced that effective January 1, 2024, most businesses will be required to electronically file Form 8300. This updated requirement is in compliance with other newer regulations that require e-filing for information returns. Form 8300 is used specifically … Read more
Need a Skilled Former IRS Attorney To Handle Your Employee Retention Credit (ERC) IRS Audit? Several ERC mills have popped up in the past year promising up to $26,000 in ERC to employers all over the country. A lot of these mills are not accountants, CPAs, or tax attorneys. They are preying on unsuspecting business … Read more
Tax Filing Gets a Digital Makeover: The Shocking IRS Update That Saves Hours! The IRS announced late last week that they are offering a new way for taxpayers and tax professionals to submit electronic relief requests for specific international documents that are past due. This is an important step in the agency’s goal to fully … Read more
Tax Agents No Longer Come To Your Door & Here’s Why Effective immediately, IRS agents will no longer be stopping by taxpayers’ homes unannounced, citing safety concerns, stress, and anxiety for both their employees and taxpayers. This announcement is a key part of a larger re-branding of the IRS through the IRS Strategic Operating Plan. … Read more
The Secret Tax Haven That The IRS Is Trying To Crack Down On Puerto Rico, an American territory in the Caribbean, has been offering tax incentives to a variety of people, especially high-income earners, hedge fund managers, and cryptocurrency traders, since 2012. Among these tax incentives are legal ways to avoid paying federal income tax … Read more
IRS Cracks Down On Tax Evaders With New Technology The latest IRS news release announced improvements, updates, and ongoing changes to IRS procedures following the Inflation Reduction Act resources granted in 2022. The agency appears satisfied with its improved service after the 2023 filing season and plans to continue to improve on its progress through … Read more
Huge Penalties For Unfiled Returns: This Is What Could Happen To You In an appeal, the Ninth Circuit court recently reversed and remanded the Tax Court’s decision that taxpayers Ritchie Stevens and Julie Keene-Stevens did not owe deficiencies or penalties for multiple tax years, despite partnership losses on their legally invalid tax returns that were … Read more
Biden’s Dark Secret: IRS Email Corroborates Whistleblower’s Claim Of DOJ Meddling IRS internal emails that were released last week provide compelling evidence of a whistleblower’s allegations that Department of Justice officials meddled in the Hunter Biden tax probe by blocking authority to freely charge Hunter Biden according to the evidence. This shocking news may have … Read more
Supreme Court Reverses Second Circuit Ruling On Right To Control Theory The U.S. Supreme Court ruled last month on Ciminelli v. United States, which was first heard in November 2022. The Supreme Court unanimously overturned the Second Circuit ruling in which Mr. Ciminelli and others had been convicted of wire fraud based on the right-to-control … Read more
Supreme Court Upholds IRS Authority To Issue Summons In Specific Collection Cases Last week, the U.S. Supreme Court unanimously ruled in favor of the IRS, upholding the agency’s authority to issue summons without prior notice in some situations. Although this authority is limited to specific collection cases, it sets a precedent for IRS power in … Read more
IRS Loses In Tax Court Failing To Find The Primary Issue On Family Ranch’s Tax Return Most taxpayers are overwhelmed at the thought of being taken to court by the IRS, which has a track record of winning a high percentage of their cases. However, as a case from earlier this month demonstrated, even the … Read more
Understanding the Tax Division’s Policy on Voluntary Self-Disclosures for Companies Last week, the Department of Justice updated their relatively new voluntary self-disclosure policy, which establishes standards for voluntary self-disclosure in corporate criminal enforcement actions. This policy indicates that when a corporation voluntarily discloses criminal conduct by one of their employees or agents, they are likely … Read more
Proof of Work to Proof of Stake: Examining the Tax Implications of Cryptocurrency Consensus Changes The Internal Revenue Service has determined that units of cryptocurrency which transition from a proof of work consensus mechanism to a proof of stake consensus mechanism are not considered a sale, exchange, or other type of income recognition event according … Read more
Silver Law PLC Attorney Jason Silver Retained as Expert Witness in Attorney Malpractice Case for Criminal Tax Trial Silver Law, PLC lead attorney Jason Silver was recently retained to act as an expert witness in a malpractice case against an attorney who allegedly committed malpractice in the representation of a federal criminal tax trial. This … Read more
Farhy v. Commissioner: Does The IRS Have Statutory Authority To Assess Section 6038(b) Penalties? This week, the U.S. Tax Court held in Farhy v. Commissioner that the IRS does not hold statutory authority under section 6038(b) to assess penalties against a taxpayer who intentionally did not file Form 5471, Information Return of U.S. Persons With … Read more
IRS Warns Against Tax Scams & Schemes In Dirty Dozen Campaign Each year, the Internal Revenue Service issues a “Dirty Dozen” campaign, in which the agency provides details regarding common tax scams from that tax year. The last of this year’s Dirty Dozen schemes were warned against this week in the most recent IRS publication. … Read more
IRS Warns of Fraudulent Employee Retention Credit (ERC) Claims Under Criminal Investigation Last week, the IRS issued a renewed warning that urges individuals to carefully review all of the Employee Retention Credit (ERC) guidelines before they claim the credit on their tax returns. Unfortunately, evidence has surfaced that ineligible people are being pushed to file … Read more
Bittner v. United States: US Supreme Court Revokes Penalty Ruling For Taxpayers With Foreign Financial Accounts Under the regulations of the Bank Secrecy Act (BSA), tax filers who hold specific financial interests in foreign accounts are required to file the Report of Foreign Bank and Financial Accounts (FBAR) with their annual tax returns, even … Read more
What Is The New IRS Service Industry Tip Reporting Program? The Internal Revenue Service issued a notice this week detailing a proposed Service Industry Tip Compliance Agreement (SITCA) program that would enable the IRS to better receive voluntary tips from employers in specific service industries. Until early May 2023, the IRS is providing the … Read more
Should Taxpayers Continue To Report All Income From Digital Assets? As the 2023 income tax return season is underway, an Internal Revenue Service (IRS) publication from this week reminded taxpayers of their obligation to report all income related to digital assets, and to honestly answer a question regarding their engagement with digital assets on … Read more
When Is A Qualified Appraisal Required For A Charitable Contribution Of Cryptocurrency? Taxpayers who want to make charitable contributions with cryptocurrency may be surprised to learn that a qualified appraisal is required when they claim a deduction on their tax return for a contribution of $5,000 or more. The IRS recently announced their findings … Read more
United States vs Banks: The Impact Of Loss Calculations On Sentencing Guidelines Under U.S.S.G. § 2B1.1 A recent case in the Third Circuit has shifted the guidelines of loss enhancement and sentencing for cases of tax fraud that fall under U.S.S.G. § 2B1.1. The court’s ruling indicates that loss enhancements are now limited to “actual … Read more
IRS Prepares An Increase Of Hundreds Of Crypto Criminal Tax Cases Although the Internal Revenue Service (IRS) has made no secret of its emphasis on cryptocurrency cases, the criminal investigation unit of the IRS has just announced that they are currently building hundreds of crypto criminal tax cases, many of which will soon be public. … Read more
FTX Cryptocurrency Exchange Files For Chapter 11 Bankruptcy, Prompting Tax Confusion Cryptocurrency exchange company FTX filed for Chapter 11 bankruptcy on November 11, 2022, prompting a flurry of questions about the tax implications for its stakeholders. FTX consists of West Realm Shire Services and Alameda Research Ltd and includes approximately 130 other affiliates. The companies … Read more
IRS-CI Releases Annual Report On Conviction Rate & Tax Fraud Enforcement Actions The criminal investigation branch of the IRS, IRS-CI, released a report last Thursday detailing their actions and successes from the fiscal year that began October 1, 2021, and ended September 30, 2022. Among their accomplishments, the IRS-CI holds its position as the sixth … Read more
Cryptocurrency & Tax Compliance: What You Need To Know If you are one of the nearly 25% of Americans who own cryptocurrency, you might be wondering how to manage your tax returns in order to remain legally compliant. Because tax compliance, tax planning, and estate planning for cryptocurrency owners can be complicated, consulting with a … Read more
IRS Confirms That Improperly Forgiven PPP Can Be Taxed In August, the IRS Chief Counsel’s Office issued an Advice Memorandum that provides guidance regarding Paycheck Protection Program loans (PPP), specifically in response to questions about PPP loan forgiveness and income tax statements. The IRS confirmed that improperly forgiven PPP loans are taxable income. Any borrower … Read more
Does Biden’s Inflation Reduction Act Really Mean 87,000 More IRS Agents Are Coming? Professionals and taxpayers have been talking extensively about the Inflation Reduction Act that was signed into law by President Joe Biden on August 16 of this year. One element of this act was $80 billion in increased funding for the IRS, which … Read more
4 Tax Schemes From The IRS’s “Dirty Dozen” List That Can Get The Average Taxpayer In Serious Trouble On June 1 of this year, the Internal Revenue Service announced its “Dirty Dozen” list for 2022, which is a list of tax avoidance schemes that taxpayers should avoid filing on their returns. These potentially abusive arrangements … Read more
When Does The Statute Of Limitations Begin If a Tax Return Was Not Previously Filed To an IRS Service Center? The Ninth Circuit Panel ruled in May that providing a tax return to an IRS agent initiates the statute of limitations even if the tax return had not been previously filed according to IRS regulations. … Read more
Aspro v. Commissioner: IRS Denies Deductions For Management Fees of C Corporation The Eighth Circuit Court of Appeals sustained a tax court’s ruling that management fees for C corporation shareholders could be taxed as dividends. This case highlights the importance of careful documentation and accuracy in preparing tax returns. Aspro v. Commissioner An asphalt paving … Read more
Supreme Court Holds IRS To Their Own Standard In April Ruling The IRS suffered a significant defeat in the U.S. Supreme Court at the end of April after a unanimous decision authored by Justice Amy Coney Barrett in the case Boechler, P.C. v Commissioner. The IRS argued that a taxpayer who filed an appeal one … Read more
IRS Announced Revisions & Updates To Voluntary Disclosure Practice Preclearance Request & Application Form Earlier this month, the Internal Revenue Service announced that they had revised and updated Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, along with its accompanying instructions. These revisions provide clarification on several issues that caused frequent confusion during the … Read more
PPP (Payroll Protection Program) Issues: Possible Civil & Criminal Liability The fact that many businesses were impacted due to the pandemic and the government responses to it, such as mandatory lockdowns, etc., was not lost on Congress. In the weeks and months following the start of the pandemic, various programs were implemented to help business … Read more
IRS CI Increases Enforcement Actions Focused On PPP & EIDL Fraud, Money Laundering & Cybercrimes The criminal investigation branch of the IRS (IRS-CI) recently released detailed statistics from the 2020-2021 fiscal year, which began October 1, 2020 and ended September 30, 2021. The results indicate a high percentage of convictions for tax fraud and financial … Read more
IRS Discusses More Extensive Oversight Of S Corporations As More Officers Underreport Compensation Arizona’s Top Tax Attorneys Explain The Treasury’s Audit & The Ramifications For Your Corporation A recent TIGTA audit analyzed whether officers of S corporations were intentionally underpaying themselves in an effort to avoid paying employment tax. As a result, several recommendations were … Read more
Ushio v. Commissioner: Taxpayers Erroneously Claim Section 1244 Stock Deduction In the recent case of Ushio v. Commissioner, a couple attempted to claim a $50,000 ordinary loss using Section 1244 of the tax code. However, since the deduction claim did not meet multiple requirements, the US tax court determined it to be invalid. What is … Read more
Sells v. Commissioner: Tax Deduction Leaves Unanswered Questions In Conservation Easement Case IRS Continues Tax Enforcement Efforts After Recent Conservation Easement Case The recent court case Sells v. Commissioner of the IRS demonstrates that the IRS will continue to aggressively pursue audits and trials when they believe a tax deduction loophole is being misused. In … Read more
Taxpayer Fails To Meet Cohan Rule’s Tax Deduction Requirements Arizona’s Leading Tax Attorneys Discuss The Recent Case Of Fagenboym v. Commissioner When undergoing an audit, it’s common to utilize the Cohan Rule, which enables a taxpayer or business to claim reasonable expenses even if they do not have receipts for those expenses. In the recent … Read more
IRS Failure To Apply Anti-Injunction Act To CIC Services Will Lead To Tax Challenges The Implications & Importance of CIC Services v. The Internal Revenue Service Recently, the Supreme Court overruled a lower court ruling affirming the use of the Anti-Injunction Act – ruling that tax experts believe will open a path to more tax … Read more
IRS Announces The 2021 Dirty Dozen List Of Tax Schemes Every year, the IRS announces its list of common tax schemes that it has encountered and is focusing its efforts on enforcing. This year, the tax agency created four categories for its usual “Dirty Dozen,” including: Pandemic-related scams Personal information scams “Ruses focusing on unsuspecting … Read more
Growing Cryptocurrency Popularity Presents Serious Tax Evasion Threat Cryptocurrency & Tax Evasion: The Biden Administration Is Proposing Stronger Reporting Requirements Cryptocurrency is quickly becoming a hot topic in the news. Business leaders and politicians are commenting on its rise and fall, its place in the economy, and – occasionally – on the security risks posed … Read more
Battat v. Commissioner: Tax Penalties Called Into Question Penalty Lacked Proper Approval: The Case Of Battat v. Commissioner Of The IRS So much of tax law is in the details – and a couple recently discovered that, to their benefit. While the IRS may be able to penalize you for failing to include some bit … Read more
Crypto Transfers Exceeding $10,000 Required To Be Reported To IRS IRS Increases Enforcement Of Cryptocurrency Reporting The Biden Administration has introduced several proposals recently to improve enforcement of tax laws by the IRS, not only to raise revenues, but also to ensure that all taxpayers pay their fair share. One of the latest proposals being … Read more
President Biden Proposes a Substantial Increase In IRS Funding The IRS Will Increase Oversight Of High-Income & Corporate Tax Returns The IRS may soon be coming for a lot of delinquent taxpayers – particularly those who have a lot of money and are taking steps to avoid their tax obligations. The Biden administration released a … Read more
Tax Laws Prepared For Enforcement By Justice Department Tax Division The IRS Has Extended The Tax Filing & Payment Deadline Due To The COVID-19 Pandemic The pandemic has made everything look a little different this year, including how we file our taxes. It’s not as easy to get in to see an accountant when offices … Read more
IRS Demonstrates Hard Fork Ruling Applications to 2017 Bitcoin Hard Fork IRS Issues Guidance On The Tax Treatment of Bitcoin “Hard Fork” In 2017, a “hard fork” was created that put Bitcoin transactions on a separate path from Bitcoin cash transactions. With the hard fork, any time a person purchased a bit of Bitcoin, an … Read more
IRS Advises Predatory Micro-Captive Insurance Participants To Leave Arrangements The IRS Continues Its Efforts To Root Out Tax Evasion & Fraud The IRS is continuing its crackdown on micro-captive insurance arrangements, and last week, it issued a new plea to participants in these schemes to leave them. The IRS is increasing its efforts to put … Read more
Court Allows IRS To Serve Summons To John Doe For Cryptocurrency Usage Taxpayers Have To Pay The Appropriate Taxes On Any Virtual Currency Gains They Make The IRS has been focusing on efforts to ensure that taxpayers are properly reporting their earnings from cryptocurrency and meeting their tax obligations. It has increased enforcement over the … Read more
Tax Court Throws Out Fraud Penalty Because IRS Agent Did Not Obtain Proper Management Approval Former IRS Tax Attorneys Discuss Recent Cases Of Tax Court Tackling Supervisory Approval of Penalties Congress approved Internal Revenue Code section 6751 as part of the Internal Revenue Service Restructuring and Reform Act of 1998. It protects taxpayers by requiring … Read more
IRS Wants Businesses To E-File When Reporting Large Cash Transactions IRS Reporting Requirements: Business Cash Transactions Over $10,000 Must Be Filed Under Form 8300 Most businesses traffic is smaller transactions. Think about your local convenience store taking in sales of $50 or less in most cases, or a Target taking in no more than a … Read more
Business Deduction Restrictions For Licensed Marijuana Dispensaries Upheld By Tax Court Experienced IRS Tax Attorneys Discuss Tax Deduction Restrictions On Marijuana Businesses Businesses may be able to sell marijuana in states where it has been made legal, but selling marijuana is still illegal at the federal level. That means that businesses that sell the drug … Read more
Tax Court Continues To Disallow Tax Deductions For Marijuana Businesses Expert IRS Tax Attorneys Discuss Tax Court Decisions on Medical Cannabis Dispensaries On February 17, 2021, The United States Tax Court issued an opinion affirming all of its prior decisions disallowing business expense deductions taken by state licensed marijuana businesses on their Federal income tax … Read more
Court Finds Penalized FBAR Tax Filings Not Excessive Expert Scottsdale Tax Lawyers Discuss The Case Of a Penalized Taxpayer For Failure to Report All Foreign Accounts On An FBAR Filing The IRS has many measures in place to crack down on taxpayers who do not report all their income – especially income from foreign accounts. … Read more
Arizona Department of Revenue Issues New Adult Use Marijuana Website Tax Lawyers Discuss AZDOR’s New Tax Assistance Website For Marijuana Businesses Marijuana continues to be a federally illegal substance even though most states across the country allow legal sales, either recreationally, medicinally, or both. In November 2020, Arizona voters passed Prop 207 to become the … Read more
Underreported Incomes and Unfiled Returns Yield Billions in Unpaid Taxes Gilbert’s Tax Attorneys Go in Detail About the Form 1099-K in IRS Findings Two days before the new year started, The Treasury Inspector General for Tax Administration (TIGTA) issued a report concluding that billions in potential tax revenue from unfiled returns and underreported income was … Read more
Learn Everything About FinCEN’s New Regulation On Crypto & Virtual Currency Scottsdale’s Preeminent Tax Attorneys Examine FinCEN’s Laws On FBAR Virtual Money Virtual currency has long since exceeded the point that everyone thought it was a novelty for risky entrepreneurs. Serious investors are now buying and keeping virtual currency, and conversations have intensified about the … Read more
Sabolic Petitioner vs. CIR: Tip Earnings under Scrutiny As our Nevada tax lawyers have experienced for many years, people who work for tips find themselves in a unique position when it comes to reporting their taxes. They are employees, yet they also generate some of their own income, independently of what their employers pay them. … Read more
Coffey vs. CIR: Tax Filing With the Virgin Islands A Statute Of Limitations Begins When The Taxpayer Files The Return In an appeals case in Coffey vs. Commissioner, the IRS sought to overturn a lower court ruling that found in favor of a couple whom the IRS had pursued for non-payment of taxes. Our Paradise … Read more
IRS to Target Tax Preparers Who’ve Failed to File their Own Returns Our Tax Attorneys Explain The New Strategy IRS has for Tax Professionals The IRS has announced a number of efforts recently to increase enforcement of tax compliance, and it has specifically said it will be going after high-earning tax filers, those who are … Read more
IRS Expansion Raises Concerns of Politicized Tax Agency Tax Attorneys Discuss Possible Link Between The IRS And Political Agendas Some Democratic leaders are now pushing for a $5.2 billion increase to the IRS for expanding its enforcement activities – an increase that, on the surface, should be met with approval, but that conservatives fear is … Read more
How is the IRS Prioritizing High-Income Non-Filers? The COVID-19 pandemic has left many struggling to make ends meet or to keep their businesses open. Meanwhile, there have been many conversations at the national level about how economic inequality and how different classes of Americans should be taxed. In a recent column from IRS executives, the … Read more
Oropeza v. Commissioner: Tax Court Decision, 155 T.C. No. 9 (2020) A tax court issued an opinion in October in favor of a micro-captive insurance owner who had been ordered to pay penalties on income reported in the 2011 tax year. Our Scottsdale tax attorneys can help explain this essential decision. Initially, the IRS found … Read more
IRS Offers Assurances of Deductibles for Partnerships & S Corporations In advance of proposed regulations surrounding income tax deductions for certain businesses, the Internal Revenue Service (IRS) issued rules that would be included if those regulations are passed. The proposed regulations aim to clarify how state and local income taxes can be deducted by partnerships … Read more
Oct. 15 Filing Deadline: IRS Increases Abusive Micro-Captive Insurance Schemes Regulations The IRS has set a deadline of Oct. 15 for those who may have participated in an abusive micro-captive insurance transaction to negotiate a settlement. That deadline is fast approaching, and the IRS is encouraging taxpayers to consult with an experienced Gilbert tax lawyer … Read more
IRS Launches Marijuana Industry Webpage on IRS.gov Marijuana continues to be a federally illegal substance even though most states across the country allow legal sales, either recreationally, medicinally, or both. Because the sale of marijuana is federally illegal, marijuana business owners must prepare their tax returns in accordance with the federal tax code and handle … Read more
IRS Warns of Higher Penalties for Tax Returns Filed after Sept. 14 This year, tax season may have seemed a bit more lax for a lot of taxpayers. The filing deadline was extended to July 15 as a result of the coronavirus pandemic and the quarantine that it prompted. Since it was harder for people … Read more
Fighting Illicit Activities through Cash Transaction Reporting A lot of criminals deal in cash in order to avoid detection by the authorities, including tax officials. But they know that if law enforcement starts looking closer into their lifestyles, they need to have a way to explain how they can afford to live the way the … Read more
12 Threatening Tax Scams the IRS Urges Consumers to Watch Out For Tax scams are common. Everyone has to pay taxes, and people looking to steal your money or information will use that process to their advantage to take what they can. They will lie to you, attempt to intercept your information, or even pose … Read more
Is an Amended Tax Return Right for Your Client? It’s easy enough for taxpayers to file an amended return using the form 1040-X. Usually, people opt to amend a return because they realize they can lower what they owed on taxes or they can get a bigger refund. Either way, it means more money in … Read more
Excessive Fines Clause in Eighth Amendment Not Breached with $12.9 Million FBAR Penalty If you invest your money in other countries, or if you save money in foreign bank accounts, you have to report those assets to the IRS and pay the appropriate taxes (if any). However, a lot of people seem to think that … Read more
IRS Announces Focus on Non-Filing Taxpayers, to Step Up Enforcement Efforts The IRS is using more tools at its disposal to focus on those taxpayers who are not filing their annual tax return. Specifically, the agency will be focusing on high-earning taxpayers who have not filed a return in recent years. Recently, the IRS has … Read more
IRS Announces It Will Pay More Visits to High-Income Taxpayers It’s common knowledge that high-income earners and business owners often find ways to minimize or avoid their tax liability. They can do it legally by hiring accountants and other tax professionals to find loopholes in the tax code to exploit, such as by moving money … Read more
IRS Implements Tax Compliance Education The IRS utilizes a number of strategies to ensure that individuals and businesses pay the taxes they owe and to do so on time. The agency provides plenty of information and education to ensure that people and businesses know what their rights and responsibilities are, and it uses a number … Read more
IRS Releases 2019 Report of Criminal Enforcement, Celebrates 100 Years of Investigations Every year, the Internal Revenue Service publishes a report with information about its criminal enforcement efforts over the preceding 12 months. This past week, the IRS released the latest report, showing that it had significant successes in enforcing tax law and levying fines … Read more
Tax Court Denies Marijuana Dispensary’s Deductions and Rules that Section 280E is Not a Penalty Provision; Dissenting Opinion Finds that Section 280E is a Penalty On October 23, 2019, the United States Tax Court issued its latest opinion regarding the federal taxation of state sanctioned marijuana dispensaries. Northern California Small Business Assistants Inc. v. Commissioner, … Read more
IRS Guidance on Tax Treatment for Virtual Currency Virtual currency is still currency in the eyes of the law. Why shouldn’t it be? You spend real money to buy it, and you can use it just like real money to buy things. You can also sell it for cold, hard cash. Yet the IRS has … Read more
New Tax Gap Estimates from IRS: Compliance Rates Remain Unchanged Every few years, the Internal Revenue Service looks at the latest tax gap: The difference between the taxes that are owed and the taxes that have been paid. The higher the tax gap, the more money the government doesn’t collect for needed programs and infrastructure. … Read more
IRS Settlement: Micro-Captive Insurance Schemes Companies often form what are known as “captive insurance companies” to protect themselves against loss. They create these companies themselves, invest their own money into them, and then use that money as insurance in case of liability, such as if they are sued or have to settle a dispute with … Read more
IRS Proclaims New Tax Filing Obligations for Specific Expatriated Individuals Just because you give up your U.S. citizenship doesn’t mean that you get out owing Uncle Sam. In an effort to get some former citizens to make good on their tax debts, the IRS has introduced a new program to certain former citizens to get … Read more
IRS Lead Development Center and Devious Tax Schemes Taxes are big money. That’s why you have so many people out there trying to scam taxpayers out of their money, and that’s why you have so many taxpayers trying to avoid paying their taxes. Too many people are looking at how they can exploit the system … Read more
Provisions of Taxpayer First Act Go into Effect Earlier this summer, President Trump signed into law the Taxpayer First Act with the goal of overhauling the IRS and improving the customer service provided to taxpayers. Specifically, the act puts limits on what the IRS can do, and it puts measures in place to better inform … Read more
IRS Sending Letters to Cryptocurrency Owners about Unpaid Taxes If you buy and sell stocks, you likely know that you have to pay taxes on any gains that you make. Just because the money came from speculation and not your job doesn’t mean that the money isn’t income in the eyes of the law. However, … Read more
Got an IRS Notice? Don’t Panic Opening your mailbox and finding anything marked from the IRS can fill you with dread – unless it’s about time for you to get a refund. But even when you’re expecting a refund, you can still have a moment where you see that letter and expect the worst. But … Read more
IRS Bars State SALT Cap Workarounds The IRS rewards people who give money to charities, to a certain extent. It allows people who contribute to charities to deduct that money on their taxes as an itemized deduction, thereby reducing their overall taxable income. What that means is that they don’t pay taxes on the money … Read more
LAS VEGAS TIP AGREEMENTS AND THE RISK OF OPTING OUT Many Las Vegas residents are nightclub, casino, or restaurant employees, and earn tip income in addition to their regular wages. Tips are considered wages and are subject to employment taxes, including Federal Insurance Contributions Act (FICA), Federal Unemployment Tax Act (FUTA), and Federal income tax … Read more
U.S. Tax Court Issues Opinion on Filing False Returns Falsifying a tax return can lead to big penalties. Not only can you be ordered to pay the full tax amount owed plus interest, but you can also be ordered to pay fines and restitution. That’s exactly what happened to one North Carolina man. The man … Read more
Nevada IRS Office Locations and Appointment Scheduling Tips If you have received a letter from the IRS notifying you that you are being audited, or if you have another tax issue that needs more in-person discussion rather than trying to navigate the maze of emails and phone calls that are routed through department after department, … Read more
United States Tax Court Issues Opinion Updating Case Law for State Sanctioned Marijuana Businesses On November 29, 2018, The United States Tax Court issued an opinion providing further guidance to state regulated marijuana businesses on the issues of business deductions, cost of goods sold, and whether a marijuana business operates a separate trade or business. … Read more
IRS Changes to Voluntary Disclosure Procedures Individuals and corporations alike have long conducted business or invested their money overseas as a means to try to avoid tax liability here in the United States. They figure that the IRS can’t monitor their activities in another country and that they aren’t really lying if they aren’t reporting … Read more
3 Ways to Find Out What the IRS Has on You You should file a tax return every year that you work or have other income to report. While you may only keep those tax returns or associated documents for a few years, the IRS will keep them for much longer. The IRS may also … Read more
Table Of Contents Can You Negotiate With The IRS On Your Own? IRS Payment Plan Requirements: Do You Qualify? Why You Should Hire a Tax Attorney for IRS Negotiations What Is An Offer In Compromise & Do You Qualify? The Risks Of Handling IRS Debt Alone Get IRS Tax Help From Former IRS Attorneys In … Read more
United States Tax Court Hands IRS Another Win Against Risk-Pooled Small Captives On June 18, 2018, the United States Tax Court issued an opinion upholding the IRS’ notice of deficiency against Reserve Mechanical Corp., f.k.a. Reserve Casualty Corp. (Reserve), a captive insurer. The opinion repeatedly references the Court’s previous ruling in Avrahami v. Commissioner, and … Read more
Tenth Circuit Upholds IRS’ Application of Section 280E Denying Business Expense Deductions to Medical Marijuana Dispensaries and References Sessions Memo, Rescinding the Cole Memo Over half of the country’s fifty states and the District of Columbia have legalized medical or recreational marijuana use. But the federal government still classifies marijuana as a “controlled substance” under … Read more
Bipartisan Changes Slated to Redesign IRS Big changes could be in store for the IRS if a legislative package that is currently receiving bipartisan support passes through Congress. Over the past year and a half, lawmakers have sought information from the American Institute of CPAs, the National Association of Tax Professionals, and other interested parties … Read more
IRS Announced End to Offshore Voluntary Disclosure Program in September 2018 Taxpayers with undisclosed foreign earnings or assets will soon run out of time to share that information with the Internal Revenue Service. The Offshore Voluntary Disclosure Program was introduced to give taxpayers a way to voluntarily resolve their foreign tax requirements without severe penalty. … Read more
IRS’s Gaming Industry Tip Compliance Program Las Vegas is an international, first-class, tourist destination. As the city has matured, Las Vegas now hosts some of the finest celebrity-run restaurants and bars. Tourism and gaming drive the Las Vegas economy, and as such, many local residents are employees of hotels, casinos, and restaurants and earn tip … Read more
IRS Posts Notice on Foreign Tax Guidelines, Says It Plans to Release More Information A lot changed with the Trump tax plan approved at the end of last year, and many individuals and businesses are scrambling to figure out how it’s all going to affect them. One of the provisions in the new tax plan … Read more
What Will the IRS Do to Enforce Collection? You can’t ignore a bill from the IRS the way you might be able to ignore a bill from the power company. The IRS won’t report you to the credit bureau and make it harder for you to get a loan or a cell phone. Instead, the … Read more
Arizona and the IRS Contracting Debt Collection Companies You can’t always pay your tax bill on time. Sometimes, you end up owing more than you expected, and you’re blindsided by the bill come April. Other times, you know what’s coming, but you just don’t have it in the budget to have more taxes taken out … Read more
Understanding the Different Notices from the IRS It’s the thing that no one wants to see when they open the mailbox: A letter from the IRS. The letter might actually be letting you know that you made a mistake on your taxes and you are getting back more money than you thought. But most of … Read more
IRS Releases New ACA Reporting Forms The year is closing in on us quickly, and before you know it, it will be time to start getting all your paperwork in order to file your taxes. If you run a business of any size in Arizona, that means you will also have to account for your … Read more
How to Protect Yourself When the IRS Files a Lien against You Failing to pay your tax bill can lead to big penalties. You can have your wages garnished, lose any future tax refund, and have your assets levied. If you fail to pay your tax bill by the date specified, the IRS may also … Read more
What are IRS Whistleblowers? You may have seen a movie or two where a “whistleblower” was at the core of some takedown of a corrupt company causing cancer by polluting the water or covering up the harmful side effects of their popular product. These movies are generally very dramatic and involve some life-or-death situation. In … Read more
Rules of Conduct for IRS Auditors Being audited by the IRS is one of the most terrifying experiences that many people can think of having. When you’re sitting across from that IRS auditor, the situation can seem even more intimidating. You may feel nervous, a little afraid, and maybe even a little angry all at … Read more
IRS Launches More Rigorous e-Authentication Process Identity theft is a growing threat in our increasingly connected society. While the Internet may make it easier to do things like pay bills or file our taxes, it also makes it easier for thieves to get sensitive personal information like social security numbers that can help them steal … Read more
Criminal Tax Evasion vs. Negligence Ignorance of the law is not a defense of the law. But ignorance of the law can show that there was no criminal intent. It can mean the difference between being found guilty of negligence or of criminal tax evasion — charges that carry very different penalties if you are … Read more
Section 530 Relief in Employment Tax Cases with the IRS As a business owner, you have to manage a lot of complicated tax issues. It is important that you hire a qualified accountant or tax lawyer to help you manage your responsibilities or you might make a costly mistake that could lead to enormous taxes … Read more
The Latest Government Efforts to Undermine Tax Evasion, Money Laundering and Corruption Tax evasion doesn’t just cost the government — it costs us all. When businesses and people aren’t paying their fair share in taxes, the rest of us either end up paying more when taxes are inevitably raised to cover what’s not being paid. … Read more
What is the Cohan Rule? You will pay a lot of money to run your business, including basic overhead like rent and utilities, as well as extras like flights to attend conferences or meals to entertain clients. Many of these expenses are deductible on your taxes since they reduce your profits. Working with an Arizona … Read more
Avoiding Innocent Spouse Relief from the Start When you are married, you share everything. You share all the money you make, and you share the liability for any debts or taxes. That means that when your spouse gets snowballed by debt, so do you. That also means that if your spouse gets on the hook … Read more
Your Rights as a Taxpayer: The Arizona Taxpayer’s Bill of Rights When most people think of taxes, they think about their obligations — what they have to pay and the fines and penalties they will face if they don’t. Most people don’t think about their rights, and some people don’t even know that they have … Read more
The IRS Takes Tax Evasion Seriously — No Matter Who You Are! The IRS Takes Tax Evasion Seriously — No Matter Who You Are! Working with a Scottsdale tax attorney can help you minimize the penalties you have to pay and potentially avoid jail time. Learn your lesson from these famous tax evaders. Scottsdale, Arizona … Read more
Repercussions of Not Filing a Tax Return in Phoenix Repercussions of Not Filing a Tax Return in Phoenix Working with a tax lawyer may be able to help you minimize the penalties you face if you fail to file your taxes. Phoenix, Arizona There’s an old saying that “In this world, nothing can be said … Read more
How A Scottsdale Tax Lawyer May Help You Get an IRS Offer in Compromise Not everyone who owes money to the IRS is a cheat who is trying to get out of their obligations. Some people don’t pay because they can’t. They fall behind, and then their financial troubles are compounded by an audit from … Read more
DEALING WITH UNFILED EMPLOYMENT TAXES Taxes can take a big chunk out of your profits. You might dread the filing of your quarterly employment taxes knowing that you are going to have a big tax bill that you simply cannot pay. Instead of working with a Utah tax lawyer, you might try to avoid the … Read more
Form 8300 and Your Car Dealership’s Reporting Requirements Any car dealer in Arizona that receives more than $10,000 in cash in a single transaction or related transactions must complete a Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business. Form 8300 is a joint form issued by the Internal Revenue … Read more
Avoiding Unintentional Structuring of Cash Transactions Structuring is a strategy used by businesses that are attempting to evade taxes by hiding large amounts of cash. With structuring, companies deposit smaller amounts of cash to avoid automatic reporting by the bank to the government. When you make a cash deposit of more than $10,000, the bank … Read more
How to Avoid Worker Misclassification Issues Running a business is no small feat. There are a myriad of laws, regulations, and restrictions to observe and follow, and it is easy to overlook essential statutes. In recent years, worker misclassification has not only been on the rise, but also made its way up on the IRS … Read more
Top 3 Stages of Tax Defense in Phoenix Arizona No one ever wants to get a letter from the IRS saying that they’re been audited, but it does happen – perhaps more frequently than you might think. If the IRS finds something suspicious in your return, you may even face a criminal investigation. If you … Read more
IRS Revised Guidelines Offshore Voluntary Disclosure Program On June 18, 2014, the IRS issued revised guidelines under the Offshore Voluntary Disclosure Program (OVDP). Under a new program called the Streamlined Domestic Offshore Procedure, if a taxpayer failure to file the foreign bank account record (FBAR) was non-willful conduct, which is defined as negligence, inadvertence, or … Read more